Expanded Opiates Testing and New CCF Form – Not for DOT


There has been some confusion concerning the implementation of the expanded Opiate Panel testing on October 1, 2017.

The expanded opiate panel will be implemented only for Federal Agencies that perform Federal drug testing in accordance with the Mandatory Guidelines for Federal Agency drug testing.

This 10/01/2017 implementation will NOT apply to drug testing as required by the DOT agencies; FAA, FMCSA, FRA, FTA, PHMSA, and USCG.

When will this expanded panel be applicable is a good question.  It will happen after the Office of Drug and Alcohol Policy and Compliance crafts and publishes in the Federal Register the Final Rule.  The Final Rule will be based upon the comments received as requested in the Notice of Proposed Rulemaking (NPRM) published earlier this year.

Can DOT regulated employers and their service agents use the OMB approved new revised CCF for testing under 49 CFR Part 40?

Not at this time because DOT has not issued a final rule authorizing testing for synthetic opioids.  Employers and their service agents are to continue using the ‘old’ CCF until further notice from DOT’s Office of Drug and Alcohol Policy and Compliance.  However, if the revised CCF is used inadvertently and the testing was consistent with Part 40, MROs are to verify and report the result according to Part 40.

If there are any questions, please direct them to myself via National Drug Screening.

Robert C. Schoening, HMC, USN (Ret.)

Consultant, Workplace Substance Abuse

Drug and Alcohol Program Manager, US Coast Guard HQ, Washington, DC (Ret.)

Expanded Opiates for DOT Testing?
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